Transfer Pricing Developments Around the World 2022' presents the most recent developments around the world in the area of transfer pricing. Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide...

The OECD's public discussion draft ‘BEPS Action 6: Preventing the Granting of Treaty Benefits in Inappropriate Circumstances' proposed a series of rules for the OECD model. The draft for Article X, ‘‘Entitlement to Benefits,'' the first five paragraphs of which are described therein as...